Income tax

The following principles were relevant in considering what constituted “expenses of management”:

(i) the expression “expenses of management” was to be treated as an ordinary English expression, which was incapable of detailed definition;

(ii) it was that expression, and that concept, which needed to be considered: the question was whether the expenditure fell within that category, and not whether it failed to fall within some other and thereby qualified by default (as it were);

(iii) the expression was a wide or fairly wide one (the difference probably made no practical difference); and

(iv) there was a distinction between the expenses of management and the general expenses of the business—an expense could fall within the latter category and not be within the former: the emphasis had to be on “management”. In addition, if one asked “management of what”, it had to be management of the business of the company, which had to be investment business or mainly investment business.